Old Mutual : Asset Owner Responsible Investment Policy

ASSET OWNER

RESPONSIBLE INVESTMENT POLICY

SEPTEMBER 2022

DO GREAT THINGS EVERY DAY

PURPOSE AND SCOPE

Old Mutual's purpose is to champion mutually positive futures every day. We work to sustain, grow, and protect the prosperity of all our stakeholders, including our clients, shareholders and the communities in which we operate. One of the ways we do this is through Responsible Investment.

Our Responsible Investment practices recognise, evaluate and incorporate material Environmental, Social and Governance (ESG) risks and opportunities into investment and ownership decisions. This complements our pursuit for long-termrisk-adjusted returns for our customers, while aligning with the broader interests of society and the environment.

The aim of this policy is to outline Old Mutual's principles for Responsible Investment (RI).

This policy applies to all South African with-profit policyholder and shareholder assets held by Old Mutual Life Assurance Company South Africa (OMLACSA) as an asset owner1.

The policy draws on the following principles, regulations and legislation relevant for our jurisdiction:

1. • The Code for Responsible Investing in South Africa (CRISA)2.
   • The King IV Report on Corporate Governance™3 (King IV). King IV includes principles (Principle 17) on responsible investment as well as a sector supplement, inclusive of asset owners as custodians of assets, who have a fiduciary duty to their customers.
   • Regulation 28 of the Pension Funds Act 24 of 1956, which requires the consideration
2. Collectively, these assets are referred to as our proprietary investment portfolios. Segregated mandates and third-party funds are excluded from the scope of this policy.
3. https://www.iodsa.co.za/page/
4. 
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   for%20Responsible,issues%20into%20their%20
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of ESG factors (affecting the long-term sustainable performance of a fund's assets) as an integral part of the fiduciary duties of the governing body of a fund.

• The Principles for Responsible Investment4 (PRI). As a signatory to the PRI, we
  are committed to the adoption and implementation of the PRI's six principles for responsible investment.
• We are a member of the UN-convenedNet-Zero Asset Owner Alliance5, continue to disclose greenhouse gas (GHG) emissions to the CDP6 and support the recommendations of the Financial Stability Board's Task Force on Climate- related Financial Disclosures7 (TCFD).

We are also directed by global good practice such as the United Nations' Sustainable Development Goals8 (SDGs) and are a signatory to the United Nations Global Compact9 (UNGC).

1. https://www.iodsa.co.za/page/king-iv
2. https://www.unpri.org/about-us/what-are-the-principles-for-responsible-investment
3. https://www.unepfi.org/net-zero-alliance/
4. https://www.cdp.net/en
5. https://www.fsb-tcfd.org/
6. https://sdgs.un.org/goals
7. https://www.unglobalcompact.org/

South Africa coordinates 30.5595° S, 22.9375° E

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OUR APPROACH AND COMMITMENT

Our approach to Responsible Investment is founded on an understanding of the investment and systemic risks posed by sustainability issues.

As a long-term investor, we believe that it is in the interests of all participants in the financial ecosystem to play

a proactive role in creating long- term sustainable outcomes for all stakeholders. Alignment on these matters is expected to create a virtuous cycle that connects the aspirations

of our clients with the long-term sustainability strategies of the firms in which we invest.

ACTIVITIES

Consideration of Responsible Investment practices in investment and ownership decisions, responsible stewardship, supporting industry Responsible Investment initiatives and contributing to Responsible Investment thought leadership and public disclosure

OUTCOME

Embedding Responsible Investment

within our investment strategy

IMPACT

An investment approach that is aligned to the broader interests of society, addressing long-term systemic risk, alongside long-termrisk-adjusted returns for our clients

Lagos,South AfricaNigeriacooordinates306°.5595°27' 55S,.5192''22.9375°N andE 3° 24' 23.2128'' E

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DRIVING REAL WORLD OUTCOMES

We invest in various asset classes to meet investment objectives as determined by our respective strategic asset allocations. These assets are managed by asset managers within the Old Mutual Group and a selection of external global asset managers. Our contribution towards real economic outcomes is therefore continued commitment in driving responsible investments exercised by the investment mandates with our appointed asset managers. Our investment strategy informs the asset managers' investment decisions and choice of investee companies selected which in turn drives real-world outcomes.

FINANCIAL ECONOMY		REAL ECONOMY

Mandates	ASSET MANAGERS	Portfolio
Old Mutual Investment Group	Investment	INVESTEE
OMLACSA	Old Mutual Alternative Investments
ASSET OWNER	Futuregrowth Asset Management		COMPANIES
	Old Mutual Multi-Managers
	Old Mutual Property.
	A selection of external global
	asset managers

South Africa coordinates 30.5595° S, 22.9375° E

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THE CORE ELEMENTS OF OUR APPROACH TO RESPONSIBLE INVESTMENT

Consideration of Responsible Investment practices, including material Environmental, Social and Governance (ESG) issues when making investment and ownership decisions.

Supporting industry Responsible Investment initiatives and contributing to Responsible Investment thought leadership across the financial services sector.

Responsible stewardship on behalf of our customers by engaging with our appointed asset managers on their Responsible Investment practices. This includes proxy voting, company and market engagements, as well as encouraging enhanced ESG disclosure and practices among investee companies.

Public disclosure on our Responsible Investment policies and practices.

We engage with our appointed asset managers on their Responsible Investment practices.

South Africa coordinates 30.5595° S, 22.9375° E

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